Learn more about the review of the regulations for pilot transfer devices

The International Maritime Organization (IMO) will review the rule about the pilot transfer devices in the International Convention for Safety of Life at Sea (Solas), as well as its complement in Resolution 1045 (27), amended by Resolution A.1108 (29). The work was included in the agenda of the Marine Stewardship Council (MSC) and submitted to the Subcommittee on Navigation, Communications and Search and Rescue (NCSR). The completion is expected in 2024. This means that the amendments will come into force in 2028, since adjustments to Solas are made every four years.

Revision of chapter 5, rule 23, of the Convention and Resolutions was proposed by China to MSC 104, in February 2021. However, due to the pandemic, the IMO Maritime Safety Committee only examined the suggestion to MSC 105 in November 2022. The measure had widespread support from the Member-States and several international entities, such as the International Maritime Pilots’ Association (IMPA), International Chamber of Shipping (ICS) and the Baltic and International Maritime Council (Bimco).

The last amendment of item V/23 was in 2006, when Brazil, USA and IMPA proposed a review of Solas, completed in 2010 together with the adoption in 2011 of Resolution A.1045 (27). The manufacturer’s certification of the pilot ladder, its fixture with the accommodation ladder on the ship’s side and the need for regular inspections of the device were some of the celebrated advances at the time.

Despite the efforts, pilots are still encountering unsafe boarding arrangements, and each year a colleague dies in service. In January, experienced pilot Francesco Galia died in the UK while transferring form the pilot boat to a large ship, due to causes as yet unknown.

According to the annual IMPA survey with pilots, 16.79% of the devices in the world were irregular in 2022. Statistics show that it is not enough to have clearer regulations. The survey shows that 87.87% of the faults were not reported to the authorities. Another example: 23.26% of the problems with combined arrangements were ladders not fixed to the ship’s side, thus in breach of the amendment included in the latest regulation.

The lack of inspection is one of the reasons for so many irregularities, but there are also cases of non-compliance that have been evaluated by the classification societies and inspectors, as pointed out by China and IMPA.

Jacob’s ladders certified by the manufacturer in breach of international rules and even with false certificates (hard to prove) are another serious issue to be settled. The draft of the new regulation no longer includes in the text the requirement of "certified by manufacturer”, reinforcing that the devices must simply meet the standards acceptable by the IMO. Moreover, it stresses that the State must demand from the manufacturers a quality control system audited by a competent authority, to be able to check the compliance of the product before its installation aboard.

“It is important that all ladders are approved by the classifying societies instead of merely having a homemade certificate“, points out Arie Palmers, pilot in the Scheldemonden region (Holland) and cofounder of the #DangerousLadders group on Facebook.

IMPA also argues that the equipment has an expiration date of 30 months after the date of manufacture. For the agency, what is most important in this revision work is to group all IMO guidelines on the subject in a single document. At the same time, the association prepared a training guide to be distributed to the ships’ crews through the International Chamber of Shipping. The guide is added to the IMPA educational poster fixed to the ships’ bridge.

In accordance with China and IMPA, regular maintenance and checking of the ladders by the mariners should be similar to those applied to firefighting and rescue equipment.

“This movement, initiated by China and immediately adopted by IMPA and other IMO members, is intended to correct the past problem of too many irregularities in the pilot transfer equipment on three fronts: stricter regulation, upgraded inspections and crew training. The IMPA safety research will confirm, in the near future, if the amendments are efficient”, says pilot Marcelo Cajaty, member of the Brazilian delegation active in the IMO for almost 20 years.

Pilot Ladder Checklist

Use this checklist every time a pilot ladder is used

1. The Pilot Ladder

Is the pilot ladder in good shape?

Check for wear and tear, missing chocks, loose steps. Check for broken steps or spreaders.

Are all steps and ropes clean and free of grease?

Is all extra equipment present and ready for use?

Lifebuoy and light

Manropes if required by pilot

Heaving line

Lifejacket

Responsible officer with communication to bridge.

Is the pilot ladder rigged to the correct height?

Has the retrieval wire been rigged correctly? (above the spreader, leading forward)

Has the pilot ladder been secured to the deck in a correct way?

Have stanchions and/or bulwark ladder been fitted and secured to the deck?

Is there adequate lighting at the pilot access point?

Is the accommodation ladder in good shape?

Check the accommodation ladder for wear and tear. Check if steps and siderails are free of grease.

Is the retrieval line of the pilot ladder rigged correctly? (Above the spreader leading forward)

Is the accommodation ladder secured to the ships side, independent of the ladder?

Is there at least 5 meters of space under the platform?

Is the platform rigged horziontally?

Are all hand railings and hand ropes rigged correctly, both inboard and outboard?

Does the pilot ladder extend 2 meters above the platform?

Have both pilot ladder ropes been secured to the ship, at 1.5 meters above the platform?

Ensure the winch reel is mechanically locked. Ensure the pilot ladder is secured to deck.

Source: pilotladdersafety.com